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Water Report - Kirtland Air Force Base Cleanup Update
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The New Mexico Environment Department (NMED) released their “2018 Strategic Plan” for the Kirtland Air Force Base (KAFB) Bulk Fuels Facility (BFF) Leak on March 6, 2018, incorporating four strategies to protect the Water Authority’s drinking water supply in the area of the contamination plume. The strategies include implementing a robust monitoring and wellhead protection program, collapsing the dissolved phase plume, and meet or exceed all public involvement requirements. In a shift from previous years, the NMED has revised Strategy 2 is now specific to monitoring natural attenuation of fuel contamination; this strategy was previously focused on characterization of light non-aqueous phase liquid (LNAPL) at the site.
The Air Force has two work plans approved with conditions by the NMED that will collect data to address LNAPL at the site and take steps to address the reduction in the number and location of groundwater monitoring wells screened at the water table. The Air Force brought online a fourth groundwater extraction well in February 2018 and added pre-treatment infrastructure at the groundwater treatment system. The pre-treatment addresses sediment and bacterial biofilm that may enter the system. The Air Force has treated over 350 million gallons of water contaminated by ethylene dibromide (EDB) since the extraction system began operation in June 2015. All four groundwater extraction wells are currently operation and treated effluent is either used for irrigation at the KAFB golf course or is injected at former water supply well KAFB-7.
NMED, the Air Force, and other stakeholders and their contractors meet periodically as technical working groups. The technical work groups are focused on the discussion of technical details regarding plume capture analysis and groundwater modeling as well as expanded investigation activities to fill data gaps in the source area and groundwater plume. The Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) Report submitted by the Air Force in January 2017 is currently in NMED review. A Risk Assessment was also submitted by the Air Force in July 2017 and that document is also currently in NMED review.
NMED and the Air Force have lead three informational meetings and one public meeting since their last presentation to the Water Authority governing board in November 2017.
STAFF COMMENTS:
The NMED 2018 Strategic Plan includes a revised strategy for the site that focuses on monitoring natural attenuation (also known as “monitored natural attenuation” or “MNA”). This is a passive remediation approach that requires an extensive monitoring well network. Additionally, natural attenuation is typically applied at sites with decreasing concentrations, following a robust technical analysis of degradation rates. Currently, 85% of the monitoring well network is submerged and not viable for monitoring natural attenuation and increasing concentrations are observed in the source area. Water Authority staff are not supportive of an MNA approach for any site, particularly the BFF site, in the service area.
The NMED strategic plan also reflects recent correspondence from the NMED to the Air Force that downplays the need for a revised plume capture analysis and no longer includes key stakeholder agreements such as RFI Addendum to address the numerous technical issues in the 2017 RFI Report. The Water Authority’s independent contractor, INTERA, Incorporated, provided their review of the RFI and the Water Authority’s concerns for the document at the Nov. 16, 2017, Water Authority Board Meeting.
FISCAL IMPACT:
None